BOARD MEETING DATE: NOVEMBER 3, 2006
AGENDA NO. 9

Approve Expenditure and Appropriate Funds Designated for Permit Streamlining to AQMD’s FY 2006-07 Budget

SYNOPSIS:

On June 9, 2006 the Board approved and adopted, as part of the AQMD's FY 2006-07 Budget, a $2,000,000 fund specifically designated for Permit Streamlining.  AQMD staff has consulted with and solicited input and recommendations from members of the Permit Streamlining Task Force Subcommittee and other industry representatives for the expenditure of this designated fund.  Based on the input received, AQMD staff has prepared a proposal for Board consideration and approval.  This action is to request Board approval to authorize expenditure of $1,645,000 from this fund to cover the five-year cost to create and fill two additional Air Quality Engineer positions and the cost for one Systems Analyst position and to hire up to four temporary Engineers and two Clerical staff to assist in processing permits and improving permitting efficiency for a multi-year period.  Additionally, $355,000 will be used to hire outside contractors to improve the efficiency of the permit processing system and to provide additional training for engineers.

COMMITTEE:

Administrative, October 13, 2006, Recommended for Approval

RECOMMENDED ACTION:

1. Approve recommendations for expenditure of $2,000,000 allocated for Permit Streamlining in the AQMD FY 2006-07 Budget.
2. Appropriate $865,000 of the $2,000,000 designated for Permit Streamlining to the AQMD FY 2006-07 Budget as shown in Attachment 1.

Barry R. Wallerstein, D.Env.
Executive Officer

Background

At the June 9, 2006 AQMD Governing Board meeting, the Board approved and adopted as part of the AQMD’s FY 2006-07 Budget amongst other permit streamlining measures, $2,000,000 specifically designated for Permit Streamlining  The Board approved permit streamlining measures included in the AQMD FY 2006-07 Budget were based on some of the suggestions received from the business community, specifically the California Council for Environmental and Economic Balance (CCEEB), Regulatory Flexibility Group, Southern California Air Quality Alliance, and Western States Petroleum Association (WSPA).  These suggestions were presented by the business community at the Budget Advisory Committee and the Permit Streamlining Task Force Meetings. 

To solicit ideas for expenditure of the $2,000,000 approved by the Board for improvements and streamlining of the permit process, AQMD staff consulted with members of the Permit Streamlining Task Force Subcommittee, other industry representatives, and AQMD staff.  Three main areas were identified for expenditure of the funds that would benefit in streamlining and improving the efficiency of processing permits.  

The three main areas are:

1. Staffing Enhancements– Hiring of Permanent and Temporary Engineers, Temporary
    Clerical Staff and a Permanent Systems Analyst, as indicated below:

• Two Permanent Permit Processing Engineers in Engineering & Compliance Office.
• Four Temporary Engineers in Engineering & Compliance Office.
• Two Temporary Clerical staff in Engineering & Compliance Office.
• One Systems Analyst in Information Management Office.

2. System Enhancements – Improve Permit Processing Systems , as indicated below: 

• Improvements to the Facility Permit System (FPS)
• Revisions to the New Source Review (NSR) system
• Updates and improvements to permit application forms
• Improvements to permit application tracking system
• Enhancements to Permitting Intranet

3.     Staff Training – Utilize outside sources to provide training to staff:

• Training for staff with outside experts and joint training with industry

II. Permit Streamlining Recommendations

1.  Staffing Enhancements

The staffing enhancements component of the recommendations is to add two new permanent Permit Processing Engineer positions, four temporary Permit Processing Engineers, and two temporary Clerical staff in the Engineering and Compliance Office, and one permanent position in the Information Management Office.

The two new recommended permanent Permit Processing Engineers would specifically work on creating additional Standard Permit Processing Templates (Templates), consolidate and update Permitting Policies and Procedures, and assist in the clean up of the NSR database.  After the Templates and Policies and Procedures are compiled and cataloged, they will be accessible for internal users on the Permitting Intranet and for the business community on AQMD’s website.  The cleanup of the NSR data will correct some of the old inaccurate NSR data and free up permit processing engineers’ time that would have been spent in the research, recalculations and correction of the data necessary to process existing and new applications.  The two new Permit Processing Engineers will also work on improving the design of application forms.

The cost of hiring the two Engineers is based on the cost for a five-year period.  After the Policies and Procedures and Templates are updated and identified, there would be ongoing maintenance of the tasks to keep the Policies and Procedures and Templates current.  The balance of the Engineers’ time after the first year would be spent on processing permit applications.  This is expected to reduce the permit backlog by 600 applications over the five year period.

The one new recommended permanent Systems Analyst position is targeted for the Information Management Office.  The position will be funded from the Permit Streamlining designated fund for the first year at $150,000 and the funding for this position for the following years will come from Information Management’s Budget. The cost of this position in the future years will be offset by the transfer of temporary services funds to salary and benefits within the Information Management’s Budget.  The Systems Analyst would be dedicated to manage the contracts for permit processing improvements that will be overseen by the Information Management Office.

The four new recommended temporary Engineers in the Engineering and Compliance Office will be hired for a limited six-month period, and will be utilized to work on reducing the permit backlog.  Due to the six-month limitation for Temporary employees, staff intends to hire Engineers who have prior permit processing experience at AQMD.   These will be either recently retired AQMD Engineers or Engineers involved in the previous Backlog Reduction Effort in 2001-02.  This way, with minimal training, Temporary Engineers can start processing of permit applications immediately. Their efforts should result in the processing of about 400 additional applications during the six month period.

The two new recommended temporary Clerical staff in the Engineering and Compliance Office will be hired for a six-month period and will be utilized to reissue approximately 8,000 revised permits for emergency internal combustion engines to be updated for compliance with Rule 1470.  If this temporary Clerical help is not available, existing clerical staff need to be assigned to complete this task and as a result there would be a negative impact on the upfront timely flow and assignment of applications received and final typing and QA/QC of permits issued.

2.  Permitting Systems Enhancements

The Permit Streamlining Task Force Subcommittee members, business community and AQMD staff have identified certain improvements needed for the Facility Permit program that is used to issue the RECLAIM permits.  The proposal is to fund $150,000 to revise the Facility Permit Program to improve its functionality and usability.  The improvements should help the business community identify changes made with each revision of the Facility Permit and improve the readability of the Facility Permit to identify the equipment permitted and the associated permit conditions.  The contract amount recommended for this task is $150,000.  This task would be contracted out by the Information Management Office and managed by the new Systems Analyst to be funded as part of this recommendation.

To streamline and expedite processing of applications submitted for Administrative Changes and Change of Conditions with no change in emissions, it is recommended to make changes to the NSR program to bypass data entry for these types of applications.  This would require programming changes to the current NSR program.  The other recommended change to NSR is to link the NSR database to the Emission Inventory database to identify facilities that have reported actual emissions over four tons a year.  This information will then be used to determine whether a facility is exempt or subject to the offset requirements of the NSR Rules.  The suggested change is to update the NSR facility data with the Emission Inventory database if the NSR facility data shows emissions less than the Emissions Inventory data. These improvements will reduce the time engineers spend on NSR-related activities and would speed up the processing of permit applications.  The contract amount recommended for these two tasks is $50,000 each for a total of $100,000.  This task would be contracted by the Information Management Office and managed by the new Systems Analyst to be funded as part of this recommendation.

There is a need to keep track of Title V and Rule 212 applications which undergo Public Notice to remind the permit processing engineers of due dates and completion dates of the Public Notices so that applications can be processed in a timely manner.  A Task Order has already been issued by Information Management staff to track Title V applications.  This tracking program has to be modified to include the tracking of applications that require Rule 212 Public Notices.  The contract amount for this task is $25,000 and would be contracted by the Information Management Office and managed by the new Systems Analyst to be funded as part of the recommendation.

AQMD staff had previously converted Permit application forms from Microsoft Word to Adobe’s Portable Document Format (PDF) and the revised forms were added to AQMD’s website.  These forms have to be updated, more functionality added, and staff trained on modifying these forms in the future.  The contract amount specified for these tasks is $40,000 and this will be managed by Engineering and Compliance staff.

To provide Engineering staff access to tools, Policies and Procedures, computer programs, links to websites, etc., a Permitting Intranet portal has been developed.  This needs to be expanded, updated, and maintained so that Permit Processing Engineers can have easy access to timely information that will help to streamline processing of permits. The amount budgeted for this activity is $20,000 and this will be managed by Engineering and Compliance staff.

Staff will return to the Board in the near term with specific contract allocations for the work to be performed in the area of system enhancements.

3.  Staff Training

To keep AQMD permitting staff current on implementation of the requirements for National Emission Standards for Hazardous Air Pollutants (NESHAPs) and Maximum Achievable Control Technology (MACT) it would be helpful to have outside regulatory or industry representatives or consultants who have expertise in a particular NESHAP/MACT to provide additional training to AQMD staff.  Further expanded training on dispersion modeling and Health Risk Assessment may also be needed for permitting staff.  It was also suggested by the Permit Streamlining Task Force Subcommittee members that training in permit processing also be made available to the regulated community.  The amount recommended to cover AQMD staff training cost is $20,000.

III.  Summary of Permit Streamlining Expenditures

The breakdown of the proposal for the expenditure of the $2,000,000 designated for Permit Streamlining is itemized in the Table below and as appropriated in Attachment 1.  A more detailed breakdown description of the recommendations is shown in Attachment  2.

Table 1

Attachments (EXE 59.5kb)

1.  Appropriation of the Portion of Two Million Dollars Fund Designation for Permit Streamlining to AQMD Fiscal year 2006-07 Budget 
2. Recommendations for Expenditure of Two Million Dollars Allocated for Permit Streamlining